Relief Regarding Shortage of Appraisers

8/8/2017 - By Sarah Oliver, CRCM

Sometimes I don’t know if I’m the only one to get the news or the last to get it. I like to think of it as the art of juggling. In my defense this has been sitting in a ‘to read’ pile for months, but still in my peripheral vision.

Basically, the federal banking agencies and the NCUA provided options to address the shortage of state certified and licensed appraisers, specifically for lenders operating in rural areas.

Option 1: Temporary Practice Permits – Would allow state certified or licensed appraisers to temporarily provide their services in states where they are not certified or licensed (subject to state’s laws). Appraisers must apply to the relevant state appraiser regulatory agency for a temporary practice permit. The certifying or licensing agency is not allowed to impose excessive fees or burdensome requirements for such permit.

Option 2: Temporary Waivers – Grants temporary waivers of requirement relating to certification or licensing of appraisers in states or geographic political subdivisions of states where there is a shortage of appraisers. And, this shortage is leading to significant delays in obtaining appraisals in connection with federally related transactions. Requests can be submitted to the Appraisal Subcommittee (ASC) of the FFIEC by appraisers, licensing agencies, regulatory agencies, financial institutions, or other persons or institutions with a demonstrable interest. This is not a quick process however as the ASC is required to issue public notice in the Federal Register granting a 30 day comment period followed by 15 days to issue a decision. The decision is further subject to approval by the FFIEC. The great news, is that the waiver would apply to financial institutions throughout the entire affected area.

Have you hugged an appraiser today (at arm’s length and with impartiality)?

*Interagency Advisory on the Availability of Appraisers - May 31, 2017 (FRB, FDIC, NCUA, and OCC) Click here for copy

About the Author | Sarah Oliver, CRCM

Sarah is a consultant in the Financial Institutions Advisory Group of Saltmarsh, Cleaveland & Gund. Her primary areas of expertise include providing compliance reviews, assisting with special research matters and consulting on deposit and lending related regulations as well as social media approaches for financial institutions.

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